FRCP, General Jurisdiction
Party waived general jurisdiction challenge, as it didn't raise it initially, and the recent S. Ct. holding in Daimler restated the already-prevailing standards for general jurisdiction.
https://www.ca10.uscourts.gov/opinions/15/15-6009.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.